Privacy Policy

This Privacy Policy sets out how The Spark of Adventure Pty Ltd (ABN 93 673 779 783) trading as Adventurous Women (referred to in this document as "Adventurous Women", "we", "our", or "us") protects the privacy of your personal information.

Please note that this Privacy Policy and all personal information collected and dealt with by Adventurous Women is subject to the Privacy Act 1988 (Cth) ("Privacy Act") and the Australian Privacy Principles ("APP") contained in Schedule 1 of the Privacy Act, as amended from time to time.

1. Scope

This Privacy Policy applies to the collection, holding, use and disclosures of personal and sensitive information provided about individuals to Adventurous Women through the use of the website, www.adventurouswomen.com.au, other applications related to Adventurous Women and any services offered or provided by Adventurous Women.

In this Privacy Policy we also explain how you can contact us if you have a query about any personal or sensitive information that we may be holding about you.

2. Acknowledgement

By continuing to use the website and/or services or when you purchase services from Adventurous Women, you acknowledge that you have had the opportunity to read this Privacy Policy. You also acknowledge and consent to Adventurous Women collecting, holding, and disclosing personal information supplied by you and retaining and/or using your personal information.

We may do so subject to the terms of this Privacy Policy, the website, any terms and conditions that apply to any goods or services that we provide to you, and any other applicable contracts.

If you provide us with personal and/or sensitive information of a third party individual, for example other people travelling with you, you will be responsible for informing the individual of the existence of this Privacy Policy and obtaining their consent for their personal or sensitive information to be provided to Adventurous Women for the purposes indicated in this Privacy Policy or as otherwise indicated at the time of collection.

3. Purpose

The purpose of this Privacy Policy is to:

• clearly communicate the personal and sensitive information handling practices of Adventurous Women;
• enhance the transparency of Adventurous Women information collection processes;
• give individuals a better understanding of the sort of personal information that Adventurous Women holds, and the way Adventurous Women uses or discloses that information.

4. Personal Information

In this Privacy Policy, "personal information" has the same meaning as defined by section 6 of the Privacy Act, as amended:

information or an opinion about an identified individual, or an individual who is reasonably identifiable:

• whether the information or opinion is true or not; and
• whether the information or opinion is recorded in material form or not.

Personal information may include:

• your name
• address (including previous addresses)
• information about you (including medical information)
• contact telephone number(s)
• e-mail addresses, bank account and credit card details
• details about flight, hotel, transfers and other related travel details
• passport details, emergency contact details
• insurance information
• payment metadata
• technical data (IP address, device info, analytics)
• other information that is necessary for the delivery of our services to you.

5. Sensitive Information

We will only collect your sensitive information with your consent and where information is reasonably necessary for one or more of our services.

We will only use and disclose your sensitive information for the primary purpose for which it was collected or a purpose that is directly related to this primary purpose and is reasonably expected.

You consent to the use and disclosure on this basis. If for example we have collected information about any medical conditions you are suffering, then you consent to us disclosing this information to our service providers (for example ground operators) if they reasonably have a need to know such information in order to safely supply services for your benefit.

We will not otherwise collect, use or disclose sensitive information about you unless required to do so by law.

In this Privacy Policy, "sensitive information" has the same meaning as defined by section 6 of the Privacy Act. Sensitive information may include information or an opinion about your health information.

Collection of Health Information for Tours

In order to safely deliver our services, we may collect health-related information from you, including through pre-trip forms. In some cases, this information may be provided in a sealed format and only accessed in the event of a medical emergency. Where this occurs, we will take reasonable steps to ensure that the information is only accessed where necessary to protect your health or safety and is otherwise returned or securely handled in accordance with this Privacy Policy.

6. Collection of personal information

In the course of regular business activity and in order to use the website and/or our services, Adventurous Women will from time to time collect, require and otherwise deal with your personal and/or sensitive information.

If you do not want any of your personal and/or sensitive information collected, you can stop using the website and/or our services at any time (subject to applicable contracts), however we may not be able to provide our services to you.

Adventurous Women collects personal and/or sensitive information from individuals in numerous ways, including for example:

• Direct collection (booking forms, emails)
• Automatic collection (cookies, analytics tools)
• Third-party sources (agents, referral partners, social media platforms)

This may be when an individual:

• visits or uses the website or social media channels;
• contracts or corresponds with Adventurous Women in person or via telephone, email, mail or directly through our website;
• makes a purchase(s) from Adventurous Women or enquires about travel arrangements with us;
• makes payment of an invoice;
• provides us with personal and/or sensitive information, including for example allowing information on social media to be shared with us or signing up for a promotion or competition or when you subscribe to receive marketing from us (e.g. a newsletter).

We may also collect personal and/or sensitive information about you from third parties or where Adventurous Women is required to do so by law.

Adventurous Women does not generally take steps to:

• verify personal and/or sensitive information about any individual disclosed to it;
• seek additional personal and/or sensitive information about any individual on the basis of information disclosed to it,

except in circumstances where it is reasonably necessary for us to do so or as may be required by law.

We note that in certain circumstances, if you do not consent to the use of your personal and/or sensitive information as outlined in this Privacy Policy or at the time of collection, you may not have access to our services and we might not be able to provide you with our services.

7. Use of personal information

Any personal information collected by Adventurous Women will be used for the purpose for which it was given to Adventurous Women, for purposes which are directly related to those purposes, for purposes which you have otherwise consented to, or for other purposes in accordance with the Privacy Act, law or this Privacy Policy.

Images and Marketing Content

During our tours and events, we may collect photographs, video or other media that may include your image or likeness. These materials may be used for promotional and marketing purposes. Further details regarding your consent to such use are set out in our Terms and Conditions.

8. Disclosure

We may disclose personal and/or sensitive information we hold to:

• our directors, officers, employees and other associated companies or related entities or organisations;
• our contracted service providers;
• credit card providers, credit reporting and fraud checking agencies;
• government, regulatory and law enforcement agencies where the disclosure is required or authorised by law;
• our professional advisors, including our accountants, auditors and lawyers;
• third party suppliers of products or services which you have selected (such as airlines, ground operators, hotels and insurance providers);
• third party travel service providers who assist in fulfilling the booking you have made; our online booking facility operator and host and others who assist in providing these services;
• third party sponsors or co-sponsors of promotions on our website. Only information collected during a promotion will be disclosed to these parties;
• advertising and social media platforms, for the purpose of creating marketing audiences (including by providing hashed contact details for matching), retargeting website visitors, and measuring the performance of our advertising;
• third parties when we contract out some of our functions and activities, such as call centre operators. In these circumstances, we prohibit third parties from using your personal information, except for the specific purpose for which we supply it.

Where applicable, we may handle or disclose personal information relying on applicable exemptions under the Privacy Act, including but not limited to, the related bodies corporate exemption and the employee exemption.

To the extent that we collect and hold personal information about our current or former employees in connection with their employment, that information may be exempt from certain obligations under the Privacy Act 1988 (Cth), including the Australian Privacy Principles. This exemption applies only to employee records directly related to the employment relationship and does not apply to personal information collected about individuals in any other capacity (for example, as customers or prospective customers).

9. Overseas Disclosure

In providing our services, we may disclose your personal and/or sensitive information to overseas recipients, including our ground operators, accommodation providers, activity providers and other travel service providers located in countries in which our tours operate. These countries may include, but are not limited to, Ireland, France, Italy, Nepal, Morocco, Japan and other destinations relevant to your booking.

We take reasonable steps to ensure that any overseas recipient to whom we disclose personal information handles that information in a manner consistent with the Australian Privacy Principles, including by engaging reputable suppliers and, where appropriate, implementing contractual arrangements that require the protection of personal information.

However, you acknowledge that overseas recipients may not be subject to the Privacy Act 1988 (Cth) or to the same level of privacy protections as apply in Australia. By providing your personal information to us, you consent to such disclosures.

Personal information may also be stored and processed overseas (including in the United States) by our CRM, booking, marketing, advertising, and productivity platforms.

10. Storage and Security

We retain personal information only for as long as it is reasonably necessary for the purposes for which it was collected, including to provide our services, maintain our customer relationships, meet legal and tax record-keeping obligations, and resolve disputes. When personal information is no longer needed, we take reasonable steps to securely delete or de-identify it.

Use of Third-Party Systems

We store and manage personal information using reputable third-party, cloud-based platforms, including our customer relationship management (CRM) system, tour booking system, email marketing tools, advertising platforms, and cloud productivity tools. Data may be shared between these systems (for example, between our booking system and CRM) to enable bookings, communications, and marketing activities. Access is restricted to authorised personnel based on role.

Security Measures

Our service providers implement a range of technical and organisational security measures to protect personal information from misuse, interference, loss and unauthorised access. These measures include encryption of data in transit and, where applicable, at rest, secure hosting environments, access controls, and monitoring of system activity. For example, booking system data is transmitted over secure, encrypted connections and stored within protected environments with restricted access, while our CRM enables permission-based access controls and additional protections for sensitive information and files.

Reliance on Third-Party Providers

While we take reasonable steps to ensure that these third-party providers maintain appropriate security standards, your personal information may be stored on infrastructure managed by those providers and is subject to their security frameworks and policies. We select providers that are widely used and considered to have robust security practices, and we periodically review these arrangements as part of our ongoing commitment to protecting personal information.

11. Cookies

We use cookies and similar tracking technologies on our website to improve your browsing experience and to better understand how our website is used. This includes the use of analytics tools (such as Google Analytics) which help us collect information about website traffic, user behaviour and interactions in an aggregated and de-identified form.

We also use analytics and tracking technologies (such as cookies, pixels, and tags) provided by analytics, advertising, and social media platforms. These support our marketing and website performance by measuring how our website is used, tracking conversions, measuring advertising performance, showing relevant content to website visitors (retargeting), and building audiences of similar users. You can manage these through your browser settings, the relevant platform's ad or privacy preferences, or by contacting us to opt out.

You can control or disable cookies through your browser settings. However, if you choose to do so, some parts of our website may not function as intended.

12. Links - External Websites

Please note that our website may contain links to other external websites. These links are provided as a convenience to you. Adventurous Women is not affiliated with these sites and accordingly has no control over, and is not responsible for, their content, activities, privacy practice or other policies. Links to external websites are not covered by this Privacy Policy.

13. Direct Marketing Communications

We may contact you using the contact details, which you provide to us in order to provide you with direct marketing communications about our services in accordance with the law.

Consent to Receive Marketing Communications

We may use your personal information to send you direct marketing communications about our tours, events and related services. We will do so where you have provided your express consent (for example, by subscribing to receive our communications), or where your consent may be reasonably inferred from your existing relationship with us (for example, where you have previously enquired about or purchased our services and would reasonably expect to receive such communications).

Unsubscribe and Opt-Out

You may opt out of receiving direct marketing communications from us at any time. All marketing emails we send include a clear and functional unsubscribe mechanism, and you may also contact us using the details set out in this Privacy Policy to request removal from our marketing lists. We will process unsubscribe requests within a reasonable timeframe.

Use of Marketing Platforms

We use third-party service providers and platforms to manage and deliver our marketing communications, including email marketing tools and customer relationship management systems. Your personal information may be stored and processed within these platforms for the purpose of sending communications and managing your preferences. We take reasonable steps to ensure that these providers handle personal information in accordance with applicable privacy laws and appropriate security standards.

14. Changes to Privacy Policy

This is our current Privacy Policy. Please note that we reserve the right to amend, modify, remove or vary this Privacy Policy at any time and without notice.

You should check this page regularly to take notice of any changes we may have made to this Policy. We may notify you of changes to this Privacy Policy via the website.

To obtain a current version of our privacy policy, please contact Adventurous Women via the contact details below.

15. Access to Personal Information & Correction of

We will respond to requests to access or correct personal and/or sensitive information within a reasonable period, and generally within 30 days of receiving your request. We may require you to verify your identity before processing your request.

We do not ordinarily charge a fee for making a request for access or correction. However, we may charge a reasonable administrative fee where permitted by law to cover the cost of providing access, and we will inform you of any applicable fee in advance.

In certain circumstances, we may refuse access to or correction of personal information where permitted under the Privacy Act 1988 (Cth), including where providing access would have an unreasonable impact on the privacy of others, where the information relates to existing or anticipated legal proceedings, or where the request is frivolous or vexatious. If we refuse your request, we will provide you with written reasons and information about how you may complain about the refusal.

16. Contact

If you have any questions or concerns about how we handle your personal or sensitive information or if you wish to access or amend personal and/or sensitive information we hold about you, please make a request in writing.

All correspondence should be directed to:

Post: Adventurous Women, P.O. Box 5073, Kenmore East, QLD 4069

Email: office@adventurouswomen.com.au

Phone: 1300 388 419

If you decide to contact us for any of the reasons above, we request that you provide us with sufficient details regarding your reason for getting in touch with us.

We note that if necessary, we will ask you to provide us with a copy of your ID, passport or other valid identity document.

17. Complaints

If you have any enquiries about this Privacy Policy or wish to make a complaint about a matter relating to privacy please contact us using the details set out above (refer to "Contact").

We will investigate and consider any complaint received by us and a response will be provided to the complainant as soon as practicable.

If you are not satisfied with the way in which we handle your inquiry or complaint in regard to your personal information, if applicable, you may contact the Office of the Australian Information Commissioner ("OAIC").

Contact details for the OAIC can be found at www.oaic.gov.au.